For this blog I am going to look at the User’s Guide and the blogs that I wrote about the CSAT Top-Screen Questions document that was published on November 20th. This initial blog will look at the three categories of Release COI; Toxic, Flammable and Explosive. I’ll be looking for differences, additional information and answers to questions that I raised in the earlier blogs.
Toxic Release COI
No new information presented in the User’s Guide. There is a good explanation of the various terms used. There is a very good step-by-step outline of how to use the RMP*Comp program to calculate Distance of Concern.
Flammable Release COI
The User’s Guide raises a new issue that I alluded to in my blog (Top Screen Questions: Flammable and Explosive Release Chemicals of Interest); fuels and how they would be dealt with. On page 34 the User’s Guide explains that: “the Top-Screen asks questions about release-flammable COI from Appendix A as well as questions about some fuels, such as diesel, that do not routinely contain Appendix A chemicals.” The guide goes on to say that various fuels are listed and the facility need only report the total amount of that fuel on site. Selecting the fuel will obviate the need to include any Flammable Release COI component of that fuel in the remainder of the Top Screen.
The User’s Guide only uses Diesel, Jet Fueland Gasoline as examples of the fuels listed. The Top Screen Questions documentdoes not list either. I have no way of knowing what other fuels are listed. The Guide is very clear that any facility reporting Flammable Release COI needs to report the fuels that they have on hand.
To my understanding, when the guide states that: “A facility that possesses only fuel(s) must: 1) indicate the type of fuel it possesses; and 2) provide the total amount of the fuel it possesses at the facility”; it means that any facility that contains fuels also must complete a Top Screen. An example on page 36 clarifies this somewhat by explaining that flammable mixtures with an NFPA rating of 1, 2, or 3 in underground tanks need not be reported. This would exempt most gasoline stations. In any case, a large number of fuel storage facilities that might have thought they were exempt from Top Screen requirements are actually required to submit a Top Screen.
In my earlier blog I noted that there was nothing in the Top Screen that covered the peculiar situation regarding propane; the fact that storage tanks of 10,000 lbs and less did not have to be counted when reporting propane inventory. There is a note on page 35 of the User’s Guide explaining that exemption. If the propane industry does not do a good job of communicating this exemption to all of their customers, I expect that there will be a substantial number of facilities that over-report their propane inventory.
Explosive COI
There is no new information in the User’s Guide about Explosive Release COI that was not covered in my earlier blog.
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